PTAB

IPR2024-00851

RJ Machine v. ARMatuRenfabrik Franz Schneider GmbH + Co KG

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1. Case Identification

2. Patent Overview

  • Title: Connecting Apparatus for Creating a Connection Between a Measuring Instrument/Valve Block and a Pipeline
  • Brief Description: The ’030 patent relates to a connecting apparatus for joining a measuring instrument to a pipeline. The apparatus uses a rotatable union nut to connect two device components, which avoids having to rotate the entire apparatus during installation as was required by prior art bolted connections.

3. Grounds for Unpatentability

Ground 1: Claims 1, 2, 6, and 7 are anticipated under 35 U.S.C. §102 over Craig.

  • Prior Art Relied Upon: Craig (Application # 2013/0187075).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Craig, which disclosed a union valve for a propane gas feed line, taught every element of the challenged claims. Craig's "union valve 8" was identified as the claimed "connecting apparatus," comprising a first connecting device (union end 13), a second connecting device (end connection 11), and a connecting unit (nut 12). Petitioner asserted that Craig's components mapped directly onto the limitations of independent claim 1, including an outwardly pointing outer flange on the first device, a male thread on the second device, and a nut unit with a female thread and an inwardly pointing inner flange. For dependent claims, Craig was alleged to show threads on the lower edge of the first device (claim 2), an outer flange on the second device (claim 6), and a shutoff valve extending at a right angle (claim 7).

Ground 2: Claims 1 and 7 are anticipated under 35 U.S.C. §102(b) over the 2008 Schneider Hook-Ups Catalog.

  • Prior Art Relied Upon: 2008 AS-Schneider Hook-Ups Catalog ("Schneider Catalog").
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that the "PR08" hook-up product in the Schneider Catalog, designed for connecting pressure instruments to a process line, disclosed all limitations of claims 1 and 7. The PR08 was described as a connecting apparatus with a "union nut" (4) interconnecting a first connecting device (impulse line 3 with nipple 5) and a second connecting device (pressure gauge valve 7). Petitioner argued this assembly met the independent claim requirements for connecting to a pipeline and a measuring instrument, having respective flanges and threads, and including a shutoff valve. The shutoff valve was shown to extend at a right angle to the apparatus's longitudinal axis, satisfying claim 7.

Ground 4/5: Claims 1, 2, and 4-7 are obvious over Parker combined with the Schneider Adaptor.

  • Prior Art Relied Upon: Parker-1 (October 2013 Parker Direct-Mount® Duo™ I.O.M. Manual) or Parker-2 (March 2014 Parker Direct-Mount® Duo™ I.O.M. Manual), and the 2012 AS-Schneider Accessories Catalog ("Schneider Adaptor").

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner asserted that Parker disclosed a connecting apparatus with a "stabilized connector" (first device), an "integral block valve" (second device), and a "union nut" that connects them. While Parker taught most limitations, its union nut was argued to be "reversed"—it has outer/male threads, whereas the patent claimed a nut with inner/female threads. The Schneider Adaptor, from the Patent Owner's own catalog, was argued to disclose the claimed conventional union nut configuration: a female thread for engaging the second device and an inner flange for engaging an outer flange of the first device.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine the references by modifying the Parker apparatus to incorporate the conventional union connection from the Schneider Adaptor. This was presented as a simple substitution of one known, equivalent union configuration for another to achieve the predictable result of a non-rotating connection, which was a well-known design choice.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success because both union nut configurations were well-known equivalents for connecting components without rotation. Petitioner argued that the choice between a male-threaded or female-threaded nut is a matter of design choice based on factors like industry commonality, cost, or accessibility, and does not change the fundamental function of the connection. The combination would predictably yield a sealed connection while maintaining the benefits of both references.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including that claims 1, 2, 6, and 7 are obvious over Craig in view of POSITA common knowledge (Ground 3), and that claims 1-3, 6, and 7 are obvious over the 2008 Hook-ups Catalog combined with the 2012 Accessories Catalog and POSITA common knowledge (Ground 6).

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-7 of the ’030 patent as unpatentable.